# " = - . 

# .. TCEQ NATIONAL 

# COMMENTS EXECUTIVE REVIEW SUMMARY
TCEQ PROPOSED COMMENTS**O~:** 

### Federal Register: January 28,2011 (pages 5110 to 5119) proposed rule to grantapetition subminedby GulfWestLandfill, 

## lX LP to exclude (ordelist) the landfill leachate from the lists ofhazardous wastes.



## OVERVIEW OF

## PROPOSAL

EPA is proposing to grant apetition subminedby GulfWestLandfill, TX, LP. To exclude (ordelist) the landfill leachate generated by GulfWestin Anahuac, Texas from the lists ofhazardous wastes. 

## COMMENTS INFORMATION TCEQ recommends EPAreconsiderthepetition for delisting the leachate from GulfWest, because ofthe inadequacies ofthe testing submittedby GulfWest to supportitspetition. GulfWest has notprovided an accurate description oflandfill construction design nor fully disclosed the characteristics and volumes of hazardous wastes disposed at the site. The basis forEPA's decision to grantthe petition should include all pertinentinfonnation available, 

## ifGulfWest is to be authorized to move to the next step ofquarterly verification testing.

• GulfWest petition for the delistingoftheir leachate does not include the waste code K174, which was accepted from Shell Chemical fromJune 5, 2001 through September24, 2002.

• Leachate volume of6,436 ydsJ 

### was incorrectlyconverted to 150,000 galtons, insteadof1,117,105 gallons; the EPADelistingRisk Assessment Softwaremay have underestimated the risk level.

• GulfWest landfill is incorrectlyclaimed to have been builtto RCRA C hazardous waste construction standards; yet, the GulfWest landfill does notcontain two or more liners and both aleachatecollection and a leachate removal systemabove and between such liners.

• GulfWest hasreceived at least 13 unauthorized hazardous waste loads since 1998, which demonstrates thatthe outdated (March 22, 1991) waste acceptancecontrol mechanismdoes not prevent acceptance of hazardous waste into the landfill.
LEAD OFFICE: Arthur Denny, MSWPermitsIWastePenmts/Office ofPennitting & 

### Registration
INTERNAL COORDINATION: R"ebecca Alvarado, Region 12/FieldOpslOCE OFFICE ofLEGAL SERVICES Susan "White, Environmental LllW/OLS 

# I DEPUTY DIRECfORAPPROVAL: RichardHyde, DeputyDirector, OPR 

# I DEADLINE: February 28, 20II

rCEQ 20374 (Rev. 5/2007) D:'n"'- I

........ I

## ATTACHMENT: COMMENTS FROM TCEQ 

## Federal Register: January 28, 2011 (pages 5110 to 5119) proposed rUle to grant a petition submitted by GulfWest Landfill, TX. LP to delistthe landfill leachate from the lists of hazardous wastes. RECOMMENDATION 

## TCEQ recommends EPA reconsiderthe petition for delisting the leachate from GulfWest, because of the inadequacies ofthe testing submitted by GulfWestto support its petition. GulfWest has not provided an accurate description of landfill construction design norfully disclosed the characteristics and volumes of hazardous wastes disposed atthe site. The basis for EPA's decision to grantthe petition should Include all pertinent information available, IfGulfWest is to be being authorized to move to the nextstep of quarterlyverification testing, COMMENT 1: 

## EPA's decision to grantthe petition is based on an incomplete list of hazardous wastes accepted atthe landfill. In Section LA., there is a listof EPA hazardous waste codes from which the GulfWest landfill has based the petition forthe delisting oftheir leachate. The listof hazardous waste codes Includes F019, F039, K017, K019, and K020. However, the list does not Include the waste code K174. The Gulf West landfili accepted K174 waste from Shell Chemical (Shell) located in Deer Park, Texas, .from June 5, 2001 through September 24, 2002. The delisting petition does not include the analysis ofthe ethylene dichloride (1,2-dlchloroethane) or vinyl chloride monomerthat make up ofthe K174'wastes, COMMENT 2: 

## EPA's decision to grantthe petition appears to be based on an inaccurate hazardous waste volume conversion. In Section III.A., the volume ofleachate is described as 6,436 cubicyards which was' incorrectly converted to 150,000 gallons. The correctvolume of leachate should be 1,117,105 gallons. The EPA may have used the incorrect volume as an input in modeling the leachate risk asseSsment. COMMENT 3: 

## EPA's decision 

# to grantthe petition is based on an inaccurate description of the landfill. In Section III.B., there is a statementthat says the Landfill was builtto RCRA construction standards for hazardous waste disposal. This statement Is inaccurate. GulfWest:s non-hazardous waste permitwas Issued on March 22, 1991 and the liner design does not meetthe hazardous waste landfill design standard (effective January 29, 1992). As

## to this date, GulfWest has not upgraded their permitto meet the 40 Code of Federal Regulation section 264.301(c) hazardous waste landfili design standards requiring each new landfili unitto contain two or more liners and both a leachate collection and a leachate removal system above ,and between the liners.
COMMENT 4: 

## EPA's decision to grantthe petition is not based on ali ofthe hazardous waste disposed atthe Gulf West landfill. Gulf West has received at least 13 unauthorized hazardous waste loads since 1998. Below is a brief summary of hazardous waste accepted intothe landfill:

• Hazardous waste from soil borings from Continental Airline was received in January 7, 1998. Waste was left in place within the landfili.
• F-listed waste from Continental Airlines was received January 26, 1999. Waste was left in place.
• K170 from Motiva Enterprises received on February 15 to 19, 1999. Waste was removed from the landfill.
• D004 from Lubrizol received on June 3, 1999. Waste was removed from the landfill.

## 0008 from DuPont Sabine RiverWorks received August 2, 2000. Waste was removed from the landfill byAugust 9, 2000. K017, K019, and K20 wastes from Shell Chemical Company received from June 1998 until September 2002. Waste was left in place and Enforcement Action was taken. F019 from Stewart & 

## Stevenson received from April 1998to February 2004. Waste left in place and EnforcementAction was taken.
• K174 from Shell Chemical Company received from June 2001 to September 2002. Waste was left in place and EnforcementAction wastaken.
• 0001, 0002, and F003 wastes from Sunoco received on June 18, 2004; Waste was left in place and a Notice ofViolation Letterwas sentto the facility.
• 0008 from Chambers County Resource Recovery and Recycling received October 2004 until February 2005; Waste was left In place and EnforcementAction was taken.
• 0007 and 0010 from BP Products North America received In December 2004. Waste was left in place and a Notice ofViolation Letterwas sentto the facility.
• 0018, K049 from Exxon Mobil received on December 17, 2008. Waste was removed from the landfill By 

## March 26, 2009.
• F037 from Exxon Mobil received on March 26 and 27, 2009. Waste was removed from the landfill byOctober 15, 2009.Investlgalion 11273715 Inv.stlgator: ARON ATHAVALEY 

# N/.A{g Texas Commission on Environmental Quality 

# © Investigation Report GulfWest Landfill TX, LP

___________ C_N_6_01_6_90_4_8_0 GULFWEST LANDFILLTEXAS RN102151099 Incldenlll Site Clas81flcaUon IHW LANDFILL SMALL QUANTITY GENERATOR SURFACE IMPOUNDMENT TANK Conducled: 0512512004

_ 

### 05125/2004 SIC Code: 9999 Program(s): INDUSTRIAL AND HA2ARDOUS WASTE STORAGE INDUSTRIAL AND HA2ARDOUS WASTE GENERATION INDUSTRIAL AND HA2ARDOUS WASTE PROCESSING INDUSTRIAL AND HA2ARDOUS WASTE DISPOSAL InvestigaUon Type: Compliance Investigation Location: COUNTY RD BElWEEN 110 ANDSH 65 Addi1ionaIID(s) : TXD980864078 39039 TXD980864078 39039 Addres.: 2601 JENKINS RD; ANAHUAC, TX Activity 

### type: REGION 12
- HOUSTON IHINCDI Case development investigation

GULF WEST LANDFILLTX LP Principal(s) : Role RESPONDENT 

### Contact's) : RoJe Partidpeted in Irrvestigallon
Regulated Entity Mail Contad

Notified

Other Staff Member's) ; 

### Role QAReviewer SupeNisor Name

Title DISTRICT ENVIRONMENTAl MANAGER DISTRICT ENVIRONMENTAL MANAGER REGISTERED AGENT OF HUNTSMAN PETROCHEMICAL CORPORATION

Name GITAARASTEH ANDY VANCE Name MR SONNY ANOZIE

MR SONNY ANOZIE

CTCORPORATION SYSTEM Phone Wor1< (713) 671-1561
Wor1< (713) 671-1561



### Associated Check List
. ::-.,,0::**'-~.--**•. Checklist Name

. ,.. IHWGENERIC OTHER ISSUES OR VIOLATlONS (10 Inyestlgatlon Comments;

.. .... Unit NamQ

### ~:~..

### '~~,~ Generic _ .•. ._i

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## r',

## GU~·~STLANOALLTEXAS.ANAHUAC

......

### MaY~5**()~** Inv.'· 273715 

### \ ) 

### Pa 6 I. INTRODUCTION On May 25, 2004, Mr, Aron Athavaley ofthe Texas Commission on Environmental Quality (TCEQ) Region 12·Houston Office conducted an Industrial and Hazardous waste (IHW) Cese Development Investigation (COl) activityfor GulfWest Landfill TX, LP. The facility is located at 2601 S. Jenkins Rd., Anahuac, Chambers County, TX 

### n514. This COl includes a records review concerning unauthorized waste disposal at GulfWest landfill facility, SWR 39039. Scope of the investigation: The scope and bacl<ground ofthis investigation are summarized as follows: In september 2002, 

### the Houston Office received letters from Shell Oil Company, and GulfVVest Landfill (AttaChment 1) concerning the hazardous characteristics ofthe biosolids waste stream 03085031 .generated at Shell Chemicars waste watertreatment plant The information provided by these companies indicated that Shell shipped hazardous waste for disposal Into GulrWest Landfill facility; however, GulfWest is not permitted

## to accept hazardous wastes for landfill disposeL Consequently, on January 16, 2003, Aron Athavaley conducted a case development investigation forthe Gulfwest Landfill facility, COl-IN 23158, which resulted into an enforcement action. Similariy, an investigetion for Shell Oil-Deer Park, COl-IN 19124, conduCted on October 22, 2002 also resulted In an enforcement action. lIIJhen the investigation reportwas submitted lor enforcement, the field investigator identified the responsible party, in CCEDS. as BroWning Ferris, Inc., CN 600263016. The case was screened for an enforcement action on January 21, 2003. The screening committee noted that Browning Ferris, Inc. is nota Viable owner entity, as the company had submitted a Certificate orTermination to the Texas Secretary of State. Consequently, atthis time, it is pertinent to change the customer number from CN 600263016 to CN6016904BO (Attachment6) and use the correct name of the company as GulfWest Landfill TX, LP. However, since the investigation is already approved in CCEOS, there are technical limitations in making the desired report changes. Consequently, this investigation reportwas prepared to update information for the enforcement action. The previous COl, IN 2315B, is updated here with respect to two outstanding noncomplianees. The first noncompliance concerning unauthOrized waste disposal in the landfill is updated for an additional scenario InVOlving shipments or hazardous waste received by GulrVVest landfill facility from Stewarts and Stevenson Technical Vehicle Systems LP, SWR 32050; this information was confirmed by Gulf West lelterdated March 1,2004to Ms. Marsh Hill of Region 12·Houslon Office (AttachmentS). The second outstanding noncompliance concerning NOR is updated 

### to have the resolved status. It. GENERAL FACILITY AND WASTE PROCESS INFORMAllON A. General Facility Information GulfWest Landfill TX, LP Facility, according to the North American Industry Classification System (NAICS) Code 

### # 99999, is a notclassifiable business. In general, the company is in the business of operating a Class 1 industrial landfill. Tha generation status for this facility is identified as nonhazardous waste generator. The facility holds aClass 1 industrial waste landfill permit

### # 39039, authorizing the receipt of third party nonhazardous wastes and disposing of them in a landfill. The on-going industrial waste generation and management activities. for which the company has prOVided notification, are included in the Notice of Registration (NOR)

### # 39039; seethe latest NOR in Attachment 2 for reviewing streams and units related to this investigation. B. Site specifiC notes During the records review, the following site specific information was noted: By letterdated November 11,2002 (Attachment 1), GulfWest notifled the Houston Office orthe Commission concerning handling of biosolidlfiltercake wastes received from Shell Chemical'swaste watertreatment plant. GulfWest reported thai, since the begInning ofJune 199B until september 24,

.. 2002, they received biosolid wasle streams, 03056072 and 03085031, generated by She.'! Chemical, Deer Park, Texas. The waste stream 03056072, when mixed with 03085031, is represented by 03085031 for the purposes of manifesting and waste recordkeeping.GULFWEST LANDFILLTEXAS· ANAHUAC 

### May 25 04 Jnv. 

### # •

### 273715 Page 30f8
In September2002, Shell noted RCRA problems concerning the hazardous waste determination for biosolid streams 03056072 and 03085031. 

### As notified 

### by Shell and GulfWest 10 Ihe Houston Office, these streamswere supposed to have the listed hazardouswaste codes K017, K019, and K020. In additlon, the biosolids also carry the waste code K 174. In June 2001, solids in the oxidation ponds at Shell Chemical's vmTP (Attachment 3) became a newly listed waste called K 174. Forthe adequate handling of K 174 in surface impoundments. Shetrsubmitted a Class 1 modification in May 2001 to the Permitting Sed-ion in Austin. The modification was to get an authorization forthe continued management of K174 In the SET Basins. Howeverwhile shipping biosolids to GulfWest, Shell did nol evaluate the "derived 

### from rule" as applied

### to K174, 

### i. e., Shell shipped K 174derived hazardous biosolid streams to GulfWest's nonhazardous waste landfill in AnhaucTexas, from June 5, 2001 through September24, 2002. As indicted by GulfWest's letterdated November 11, 2002 (Attachment 1) , the landfill leachate is always sent to SFI hazardous injection facility in Calcasieu, Louisiana. After becoming aware of the "derived from" listing codes, GulfWest is using appropriate maniresling procedures to ship the leachate es hazardous waste. The notification problem associated with the leachate handling is eddressed in the violation section ofthis report. The annual waste summaries submitted to the Commission by Shell give an idea ofbiosolid waste quantities (Attachment4) shipped to GulfWesl During the calender year 2002, Shell shipped the biosolid waste 03085031 in the estimated amount of 34,302 tons orat an average rate of94 tons a day. During 2001, the same shipment rate was about 102 tons perday. GulfWest letter dated March 1, 2004 10 Ms. Marsh HIli of RegJon 12·Houston Office (Attachment 5) documents a potential release of hazardous waste-F019 into their nonhazardous Class 1 landfill. During the period ofApri1"15, 1998 through February 26, 2004, GUlfWest received Mercake shipments from Stewart and Stevenson Technical Vehicle Systems lP (Stewart and Stevenson), SWR 32050. In April 1998, Stewart and Stevenson classified Ihe filtercake as a Class 1 wasta without considering the applicabilityof the listed code F019. HOW'ever, in February 2004. Stewartand Stevenson discovered thatthe waste stream should have carried the listed code F019. The volume af this hazardous waste stream, according tothe GulfWest letter, is approximately 600 cubic yards, III. SUMMARY OF OUTSTANDING ALLEGED NONCOMPLIANCES During the investigations condUcted on January 16. 2003 and May 25. 2004. the following alleged noncompliance was noted and remains unresolved:
1. 30 Texas Administrative Code (TAG) 335.2 (b)
- Waste Disposal at an Unauthorized Facility (CategoryAS) Receiving hazardouswastes rrom Shell Chemical Company, SVIIR 30007: Since June 1998. Gulf Westwas receiving for landfill disposal the biosolid waste streams, 03056072 and 03085031, generated by Shell Chemical, Deer Park. Texas. The waste stream 03056072, when miXed with 03085031, is represented by 03085031 for the purposes of manifesttng and waste recordkeeping. During the calenderyear 2002, Shell shipped the biosolid waste 03085031 in the estimated amount of 34,302 tons or al an average rate of 94 tons a day. During 2001, the same shipment rate was approXimately 102 tons per day. In June 19S8, however, SheH failed to perform adequate hazardouswaste detBm'lination rorthese wastes: The biosoliu waste streams should have carried the waste codes K 017, K019. and K020 In accordancewith the l.derived from' rule in 40 CFR 261.3. In addition, In 

### May2001, Shell failed to evaluate the impact of K 174 handled in their surface Impoundment units 038,039, and 040 

### onthe blosolid streams. Thus. in May2001, the biosolld wasle streams also carried the waste code K 174. On September24,2002, Shell notified Gulf\Nest of the noted RCM problems and stopped sendlng:

..

### _:c·~ 

## :.. shipments'

# to them. Presently, the blosolid streams are being shipped toWaste " 

### "':"!. :, ,.,",:, '. ' Management hazardous waste landfill facility in louisiana. ..,_.... Receiving hazardous wastes from Stewart and Stevenson, SWR 32050: GulfWest leiterdated March 1, 2004 to Ms. Marsh Hill of Region 12·Houston Office documents a potential release ofhazardous waste-F019 into their nonhazardous Class 1 landfill. During the period ofApril 15, 1998 through February 26, 2004, GulfWestwaste received filter

### cake shipments 'rom Stewart and Stevenson Technical Vehicle Systems LP (Stewartand Stevenson). In AprtI1996, Stewart and Stevenson dassified the filtercake as a Class 1 waste withoutconsidering the applicability

### 01 the EPA listed code F019. However, in February 2004, Stewartend Stevenson discovered thatthe waste streem should heve carried the listed code FOI9, The volume ofthis hazardouswaste stream received in the noted time interval, according to the GulfWest records, 

### is epproximetely 600 cubicyards. 

# ;:;:::1 GUL,PWeST LANDFILL TEXAS· ANAHUAC

# MaJ,~~~ Inv, #·273715

# P.(~t!J6

Since. GulfWest 

### landfill is designed with protective measures to prevent ground water contamination, no specificcorrective actions are requested 

### rorremoval ofwastes atthis time. The case is, however, SUbject to TCEQ enforcement action. IV. SUMMARY OF ALLEGED NONCOMPLIANCE RESOLVED During the investigations conducted on Jenuary 16, 2000 and May 25, 2004, the following alleged 

### noncompliancewas noted and later resolved: 1. 30 Texes Administrative Code (TAC) 335.6(c)-Notification recuirements (Category C3) Notice of Registration (NOR) update: The lacility should update the latest NOR forthe following 

### waste streams: (i)

### The leachate collectiontank unit 007 stores the landfill**~achate.** 

### Awaste stream number should be assigned to this leachate; (ii) 

### The stabilization basins, units 003, 004, 005, and 006, are used to mixthird party Class 1 industrial wastes. Upon mixing and stabilizing, a new stream is generated. This stream shoukt be 

### added to the NOR. On May 25, 2004, the Field Investigator reviewed tile GultWest NOR. 

### As requested NOR changes are made to the NOR, this noncompliance is considered resolved as of May 25, 2004. ALLEGED VIOLATIONS NOTED AND RESOLVED 

### Resolution Date: July 08 04 Track No: 16937 30 TAC Chapter 335.6(c) Alleged Violation: Investigalion: 23158 Comment Date: 01130/2003 30 Texas Administrative Code (TAC) 335.6(c)-Notification requirements (Category C3)

. Notice 

### 01 Registration (NOR) update: Ths facility should update the latest NOR 

### forthe following waste streams: (i) The leachate collection tank unit007 stores lhe landfill leachate 

### Awaste stream number should be assigned to lhis leachate; (ii) 

### The stabilization basins, units 003. 004, 005, and 000, are used to mixthird party Class 1 industrial wastes. Upon mixing and slabilizing, a new stream is generated. This stream should be added to the NOR. Investigation: 273715 Comment Date: 06124/2004 30 TAC 335.6(c)
- Notification Reculrements NOR update: The facility should updets the latast NOR forthe lolowing waste 

### streams: (i) 

### the leachate colleetin tank unit007 stores lhe landfill leachate. Awaste stream numbershould 

### be assigned to this leachatel (Ii) 

### the stabillzation basisn, units 003 - 006 are used to mix

### third party Class 1 industrialwastes. Upon mixing and stabilizing, a newwaste slream ;s generated. This stream should be added to the NOR. On May 25,2004, the NOR was revieWed in the R12 office. All the.lllquested NOR 

### updates had been completed. Thls,yjotation is considered resolVed,**p.~tol** 

### May25, 2004 ' , ,**c~,_**

.....**:::-~_,t;;:.::** '

## ....**~,'.** 

### This resolution is after the initial NOE was sent (4.3.03) and screening occured onGULF WEST LANDFILLTEXAS· ANAHUAC 

### May 25 04 Inv. #·273715 Page50f6 January 21, 2004. Due to a Central Registry issue the case was returned. Recommended CorrectiveAction:

. The facilityshould updalt:tthe latest NOR forthe noted waste streams.

Resolution: This violation was cited in a NOE which was issued from an investigation conducted on 1/1612003. The Enforcement Action Referral was sentto the Enforcement DivisIon. About6f15J2003. the company changed Regulated Entitiy Numbers (RN} in Central Registry. On 211012004, the Enforcement Division referred the case back to Field Ops stating that CCEDs had the customerfor the investigation as Browning-Ferris, Jncwhich had not been aviable entity since 1997. Field Ops redid the investigation on 5125/2004 and this violation was resolved as of512512004. Track No; 163678 Resolution Date: September02 04 30 TAC Chapter335.2(b) PERM.IT SW-39039-001 Violation ofSection II. 

### A. and Section VII. C. Alleged Violalion: Investigation: 273715 Comment Date: 0611512004 1. 30 Texas Administrative Code (TAC) 335.2 (b)
- Waste Disposal atan Unauthorized Facility (CategoryAS} Receiving hazardous-wastes from Shell Chemical Company, SWR 30007: Since June 199B, GulfWestwas receiving for landfill disposal the biosolid waste streams, 03056072 and 03085031, generated by Shell Chemical, Deer Park, Texas. The waste stream 03056072, when mixed with 03085031, is represented by 030B5031 for the purposes of manifesting and waste recordkeeping. During the calenderyear 2002. Shell shipped the biosolid waste 03085031 In the estimated amount of34,302 tons oratan average rale of94 tons a day. During 2001. the same shipment rate was approximately 102 tons perday. In June 1998, however. Shell failed to perform adequate hazardous waste determination for these wastes. The blosolid waste streams should have carried the waste codes K017, K019, and K020 in accordance with the (,derived from' Nle in 40 CFR 261.3. In addition, in May 2001, Shell failed to evaluate the impactof K 174 handled In their surface impoundment units 038, 039, and 040 on the biosolid streams. Thus, in May 2001, the biosolid waste streams also carried the waste code K 174. On September24,2002, Shell notified GulfWest ofthe noted RCRA problems and stopped sending shipments to them. Presently, the biosolid streams are being shipped to Waste Management hazardous waste landfill facility in Louisiana. Receiving hazardous wastes from Stawart and Stevenson, S'NR 32050: Gulf West letterdated March 1, 2004 to Ms. Marsh Hill of Ragion 12-Houston Office documents a potential release of hazardous waste-F019 into their nonhazardous Class 1 landfill. During the period ofApril 15, 1996 through February 26, 2004. GUlf West waste received tilter cake shipments from Stewart and Stevenson Technical Vehicle Systems LP (Stewart and Stevenson) In April 1998, Stewart and Stevenson classified the fillercake as a Class 1 waste without considering the applicability ofthe EPA listed code F019. However, in February 2004, Stewartand Stevenson discovered that the waste stream should have carried the listed code F019. The volume ofthis hazardouswaste stream received in the noted time interval, according to the Gulfl/vest records. is approximately 600 cubic yards. Recommended Corrective Acllon: Take adequate measures in evaluating the wastes accepted for landfill disposal end detect unauthorized shipments prior to on-site landfill operations. Resolutlon: This violation is a past eventwith no opportunity for compliance.**GlJ·~F** 

### WEST LANDFILLTEXAS· ANAHUAC

## MaY.~S04 lnv. 

### #

- 273715

## P~~ 6 of6**~_.**



### ,**l~·**
Signed
---

_ Environmental Investigator

Signed

_ Supervisor



### Attachments: (in 

### orderofflnal reportsubmittal) _Enforcement Action Re<luest (EAR) _Letterto Facility (specify type) :

_ lrwestigation Report _Sample Analysis Results _Manifests _NOR Date

_

Dilte

_



### _Maps, Plans, Sketches _Photographs _Correspondence from the facility _Other (specify) ,

I _ . _ • I" ...•. !**,4-_~_ .~.**  .4 ::**~;c~-;·** . :\'==-:

### ;~1~~i~~: 

# . ·'d**W~_** •

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